| Comment Number: | EM-023165 |
| Received: | 3/16/2005 12:41:03 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| No Attachments |
Comments:
Comments concerning proposed Department of Defense Office (DOD) of Personnel Management (OPM) - National Security Personnel System (NSPS). Written and submitted via email on 16 March 2005. In general, have read and re-read the 53 pages on the proposed rule called NSPS several times and cannot see where implementation of these changes will produce a better DOD civilian workforce. What NSPS makes abundantly clear is that supervisors and managers will have almost absolute control of their civilian employees. Civilian employees, on the other hand, seemingly will have NO protections against any type of abuse of power on the part of management. NSPS is seemingly attempting to allow management to have absolute power over their workers without providing any protections to stem or curb abuses. This system changes the way workers will be paid, evaluated, promoted, assigned, etc. It allows managers to make the decision, leaving the door wide open for abuses such as: favoritism, discrimination, and harassment - just to name a few. Specific areas of concern: Subpart C - Pay. Every civilian, who works for the government, is entitled to fair and equitable pay. Under the current system all employees know when and how they are going to be paid. Under NSPS, DOD will be able to determine when and if they want to give employees any pay increases. It is my understanding that FAA workers have not received so much as a cost of living pay increase in over two years - this will most likely happen to DOD employees. Plus NSPS allows employers to decide who gets a pay raise and who does not again allowing for favoritism and discrimination. Subpart D - Performance Management. NSPS appears to be taking away any and every avenue for the employee to appeal an inaccurate or unfair evaluation. Since a substandard performance rating could result in a decrease in pay or even being fired, NSPS needs to ensure employees have access to an independent grievance and appeals process. Without these written guarantees, employers will have almost autonomous power over their employees. Subpart F - Workforce Shaping. The current system ensures that performance and longevity are factors taken into consideration before deciding who goes and who stays. NSPS allows managers to decide and does not lie out any clear guidelines for making any determinations on which employees will get the boot. Subpart G - Adverse Actions. It seems that due process and fairness would require an independent body to review major decisions on the part of management. However, NSPS does not seem to have this written into these proposed changes. The current system for address these matters need to be retained in this document. Subpart I - Labor Management Relations. There are a number of assurances written into this document maintaining employee rights to organize and engage in collective bargaining. However, DOD seemingly has the right to completely disregard anything presented to them by these units. As a footnote - I retired after 20 years of faithful and honorable service in the United States Navy. The very idea that NSPS proposes to give DOD the right to "deploy" me whenever and wherever they please is absolutely abhorrent. Did my military duty - do not need or want to live as though I was still in the military now that I am a government employee. Plus, while in the military, if sent into a war zone we were paid hazardous duty pay, separation allowance, paid no taxes on salaries drawn while in the war zone - the list goes on. There is nothing in NSPS giving any of these "benefits" to the civilian workers if sent into a war zone.